Privacy notice for suppliers

Privacy notice for suppliers according to art. 13 / 14 of the UE Regulation 2016/679 (GDPR)

This privacy notice concerns the processing of personal data of Suppliers and Business Partners (hereinafter “Supplier(s)”) of Avion Company S.p.A. It applies to individuals or partnerships as well as to personnel and employees of corporate entities. Avion Company S.p.A. does not carry out marketing activities towards suppliers who are natural persons. Personal data are processed in accordance with the provisions of EU Regulation 2016/679, Legislative Decree 101/2018, and as indicated in this notice.

Data Controller

Data controller is Avion Company S.p.A. with registered office in via G. Di Vittorio 37, Peschiera Borromeo (MI) – 20068 Italy, e-mail: privacy@avioninternational.com

Information on data processing

Provision of personal data is necessary for the establishment, execution and proper management of the contractual relationship with the Supplier and for the fulfillment of legal obligations.

Categories of Personal Data	Purposes of processing	Legal basis of data processing	Data retention
General &Contact Data: name, contacts (email, phone, mobile phone), name of the company, address. Contractual Data: company position, skills, goods handled, events relating to the contract or to the business relationship. Correspondence: any information and documentation contained in correspondence that relates to the business relationship. Performance: site visits, quality and quantity of work performed, complaints and disputes with possible litigation Data from records and public registers. Possession of certifications and legal requirements *Payments, financial & solvency information.** Generally, the data marked with an asterisk * can be qualified as “personal data” if the Supplier (sender or recipient) is a natural person.	a. Establishment and management of the contractual relationship, and in particular: management and reply to offers, quotations and negotiations; management and execution of obligations arising from the contract; management of orders with shipment tracking and contacts with sender(s) and recipient(s); for administrative management and customs procedures;	Performance of pre-contractual requests and contractual obligations	Duration of the contractual relationship and for ten years after the closing of the contractual relationship pursuant to articles 2214 and 2220 of the Italian Civil Code.
	invoicing, archiving and other purposes related to obligations provided for by law; preservation of company assets, security of information systems, transport safety and security of Avion personnel, customers, carriers, partners and suppliers, and related legal obligations; Execution of company procedures, internal management and management reporting, management of financial and insurance services.	Compliance of legal obligation / legitimate interest
	b. Claims and litigation management, risk control (fraud, insolvency, etc.),	Legitimate interest
	c. Statistical purposes (market research, profitability and/or statistical analysis).	Legitimate interest
	d. Marketing or promotional purposes (Suppliers who are natural persons are excluded), including the proposal of access to the My Avion reserved area, commercial initiatives, presentation of new products, services and offers.	Legitimate interest	Until unsubscription
	e. Newsletters and Informative Communications	Legitimate interest	Until unsubscription

Processing procedures

The processing is carried out by the Controller through its own authorized personnel and/or by external data processors and their appointees, in compliance with the regulations in force. The Controller has adopted the necessary technical and organizational data protection measures to prevent unauthorized access, alteration, dissemination, loss or destruction of personal data.

Disclosure of personal data to third parties and sources of data collection

Within the limits relevant to the processing purposes indicated, the data may be communicated to companies and branches of the Avion Group, transporters, logistics, air or maritime carriers, warehouses, customs authorities, insurance companies, credit institutions, software and IT companies and subcontractors, credit recovery companies, consultants, certification bodies, freelancers, representatives, retailers, agents and authorized brokers, as well as the competent authorities such as Customs, ENAC, Revenue Agency, Prefecture, Police Headquarters, Consulates, Police, Carabinieri, Authority for the protection of environmental, cultural and / or health, Judicial Authority, for the fulfillment of the law. These subjects may also be the source of collection of data relevant to the purposes of processing indicated above.

Data transfers outside the European Economic Area (“EEA”)

In case of international shipments to or from third countries at the request of or for the benefit of the data subject, the data subject’s consent is not required for the transfer, provided that at least one of the following conditions set forth in Article 49(b) and (c) GDPR is met:

-the transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of pre-contractual measures taken at the data subject’s request;
– the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person.

Alternatively, we will put in place appropriate safeguards to ensure that your personal data are adequately protected at destination, verifying that the data is transferred to a country that provides a level of protection equivalent to that established by the GDPR. Alternatively, we will take appropriate measures, such as entering into specific agreements with data recipients, adopting the European Commission’s model clauses, or that other safeguards are in place. In other cases, consent will be required.

Data Subject Rights

Data subject may exercise his/her rights at any time, and in particular:

confirmation of whether or not personal data concerning him/her are being processed and to obtain access to the data and the following information: purpose of processing; categories of personal data; recipients; storage period; existence of the right to rectification, cancellation and limitation; origin of data not collected from the data subject;
the cancellation or rectification of inaccurate personal data concerning him/her and/or the integration of incomplete personal data if he/she so wishes, also by providing a supplementary declaration;
the limitation of processing consisting in the blocking of data processing for the period necessary for the required verifications in the hypotheses foreseen by the regulations in force;
the portability of the data provided to the Controller including the direct transmission of the data to another data controller, the Controller shall deliver the personal data available on electronic format for common use to allow migration to other media;
- opposition at any time to processing based on the legitimate interest of the Controller;
- revocation of consent, where the processing is based on such legal basis.

Exercise of data subject’s rights and complaints

Data subject may exercise his/her rights at any time by contacting the Controller by sending an email to privacy@avioninternational.com without any formality or payment of any additional cost. Every request received by the Controller will be taken into consideration after verifying the identity of the person entitled and safeguarding the rights of third parties. Requests will be satisfied as soon as possible and in any case within thirty days, except in the case of objective difficulties which will be communicated in writing within this period. In case of dissatisfaction on the modalities of processing and complaints and for any clarification data subject may write to the Controller, without prejudice to his right to apply to the Authority responsible for the protection of personal data www.garanteprivacy.it.

Peschiera Borromeo (MI), 9 March 2021

AVION COMPANY S.p.A.